Scope of Practice
From a scope of practice perspective, a pharmacist may conduct a comprehensive medication review for a patient according to the Standards of Practice.
Establishing the MedsCheck program eligibility criteria for patients and pharmacists falls under the mandate of the Ministry of Health. Information related to billing, such as submitting a claim for reimbursement and the required paperwork, can be found in the materials available on the Ministry of Health website, such as the Professional Pharmacy Services Guidebook, and the Ontario Pharmacists Association’s MedsCheck Resources. Additional questions can be directed to the ODB HelpDesk or [email protected].
For example, the Ministry of Health may require the pharmacist to meet certain education requirements to be eligible to receive reimbursement for providing a Ministry of Health professional service program. As pharmacists are self-regulated professionals, the College cannot interpret the Guidebook on behalf of a registrant and/or determine whether the Ministry’s criteria have been met.
Yes. The Drug and Pharmacies Regulation Act (DPRA) s149 permits pharmacy students and pharmacy technician students under direct supervision of a Part A pharmacist who is physically present, to perform their respective therapeutic and/or technical checks to dispense prescriptions. Students should document their actions, reflecting which step(s) of the process they performed and are responsible for, on the dispensing record.
The College does not require a specific documentation method or format for “signing” a prescription by the student or the supervising pharmacist. This depends on the software, technology, and workflow in place, which differs between pharmacies. As with any activity performed by a student, there must be a way to readily identify the supervising pharmacist who is responsible and accountable for the student. The Designated Manager/pharmacy administrator should establish expectations and operational procedures on documentation to support students and supervising pharmacists. Refer to the Supervision of Pharmacy Personnel Policy for more information. Consideration should be given to situations outside of the College’s mandate, such as third-party billing and audits. Students should consult their educational institutions for guidance on documentation during experiential learning.
Yes. Federal regulations authorize pharmacy technicians to accept verbal prescriptions and to transfer prescriptions for drugs on the Prescription Drug List. These regulations define pharmacy technician as a person who is registered or otherwise entitled under the laws of a province to practise pharmacy and is practising in that province.
In Ontario, students enrolled in a pharmacy technician education program can practice pharmacy under the supervision of a Part A pharmacist without being registered because of an exception in the Regulated Health Professions Act. Since they meet the definition of pharmacy technician for the purposes of the regulations, they can accept verbal prescriptions and transfer prescriptions.
Pharmacy technicians, pharmacy technician students, and intern technicians cannot perform either of these activities for prescriptions for controlled substances (narcotics, controlled drugs, and benzodiazepines & other targeted substances).
For a summary of the legislation, refer to the Legal Scope of Practice & Authorized Acts chart.
Yes. Federal regulations authorize pharmacists to accept verbal prescriptions and to transfer prescriptions. These regulations define pharmacist as a person who is registered or otherwise entitled under the laws of a province to practise pharmacy and is practising in that province.
In Ontario, students enrolled in a pharmacy education program can practice pharmacy under the supervision of a Part A pharmacist without being registered because of an exception in the Regulated Health Professions Act. Since they meet the definition of pharmacist for the purposes of the regulations, they can accept verbal prescriptions and transfer prescriptions.
Verbal prescriptions can be accepted for drugs on the Prescription Drug List (“prescription drugs”) and certain controlled substances — specifically controlled drugs, verbal prescription narcotics, and benzodiazepines & other targeted substances.
For transfers, prescriptions for prescription drugs can be transferred by a pharmacy student to another pharmacy student or to any registrant of the College. However, prescriptions for benzodiazepines & other targeted substances must be transferred to another pharmacy student, intern or pharmacist. Importantly, any of the additional activities permitted by the Health Canada subsection 56(1) class exemption under the Controlled Drugs and Substances Act cannot be performed by pharmacy students or interns, because the exemption defines pharmacist as a person “who is entitled under the laws of a province or territory of Canada to practise as a pharmacist.”
For a summary of the legislation and exemption, refer to the Legal Scope of Practice & Authorized Acts chart.
Yes. Pharmacy professionals are authorized to accept verbal prescriptions under federal regulations. The regulations outline what practitioners can order verbally and the details which must be included on the written record of the transcribed prescription. However, the regulations do not address the workflow or operational aspects that might be encountered in practice.
Regardless of who performs the ‘task’ of phoning in the prescription, the receiving pharmacy professional is responsible for determining that it is valid and authentic. If there is uncertainty about whether a practitioner with prescribing authority has truly initiated and authorized the order (being communicated via an intermediary), the pharmacy professional should follow up with the prescriber directly. The decision as to what is sufficient to verify the legitimacy of the prescription, considering the circumstances at hand and the best interest of the patient, rests with the professional judgement of the registrant who should document their rationale.
Pharmacy professionals should be especially diligent when receiving verbal orders due to the increased potential for errors.[1] Prescribers should consult their regulatory body for guidance on issuing verbal prescriptions.
Yes. A pharmacy professional may decide to administer a substance that is not listed in Schedule 2 of O. Reg. 256/24 to a patient via the intranasal route, without needing delegation of authority (e.g., a medical directive). Refer to Appendix A of the Administering a Substance by Inhalation Guideline as it explains that “intranasal” administration of a substance is not a controlled act and therefore is not restricted to health professionals or require enabling regulations.
With inhalation, the drug is intended to be delivered to the epithelium lining the lower respiratory tract. With intranasal administration, the drug is intended to be delivered to the mucous membranes lining the nasal passages. If a pharmacy professional decides to administer a substance by the intranasal route, this should still be done in accordance with the Administering a Substance by Inhalation Guideline, Code of Ethics and Standards of Practice.
Yes. Administering a substance by injection is a “controlled act”, as defined in the Regulated Health Professions Act (RHPA), that may only be performed by an authorized health professional. There are, however, provisions in the RHPA that permit “a person” to perform a controlled act “in the course of rendering first aid or temporary assistance in an emergency” even if they are not an authorized health professional.
Also, the province’s Good Samaritan Act provides protection from liability for a pharmacy professional “who provides emergency health care services or first aid assistance to a person who is ill, injured or unconscious as a result of an accident or other emergency”.
Therefore, in the event of a medical emergency, a pharmacy professional may decide to administer a substance (that is not listed in Schedule 1 of O. Reg. 256/24) to a person, without delegation of authority (e.g., a medical directive), while waiting for emergency medical services. This should still be done in accordance with the Administering a Substance by Injection Guideline, the Code of Ethics and Standards of Practice.
Pharmacy professionals may dispense or compound drugs pursuant to a prescription issued by a veterinarian for an animal, provided they have the knowledge and skills to do so safely and in accordance with the Standards of Practice. The Drug and Pharmacies Regulation Act (which governs dispensing and compounding by pharmacy professionals) defines ‘prescription’ as “a direction from a prescriber for the dispensing of any drug or mixture of drugs for a designated person or animal.” Importantly, the patient is the animal, not the owner/client, and collaboration between veterinarians and pharmacists is essential for the safety of their animal patients when providing these services.
However, it is important to recognize that additional factors are necessary to consider since the use of a drug in humans cannot be equated to the use of the same drug in animals1. Differences in the anatomy and physiology of animals can result in differences in a drug’s pharmacokinetic and pharmacodynamic properties and species-specific toxicities. The provision of care to animals requires specialized training and knowledge, and pharmacists have a professional responsibility to acknowledge when they lack sufficient competency to provide this service.
Other professional pharmacy services, such as prescribing (I.e., initiating, adapting, and renewing prescriptions) or administering substances, are governed by the Pharmacy Act. Regulations under this act define ‘prescription’ as “a direction from a prescriber directing the dispensing of a drug or mixture of drugs for a specific patient” without including ‘animal’. It presents a significant risk to animals for a pharmacist to provide care beyond the dispensing or compounding of a veterinary prescription. As such, the regulations that include these services in a pharmacist’s scope of practice, such as the recent change permitting prescribing for minor ailments, apply only to human patients.
Reference
Billing a prescription to a third party payer does not have any bearing on the scope of practice of pharmacy defined by the Pharmacy Act and Ontario Regulation 256/24. Vaccines (listed in Schedule 3 of the regulation) may be administered under independent authority in accordance with the Administering a Substance by Injection Guideline. Vaccines listed in Schedule I of the NAPRA Drug Schedules require a valid prescription in order to be dispensed prior to administration.
To receive reimbursement for influenza, which is a Schedule II vaccine, a claim is submitted to ODB via the Health Network System. This requires the pharmacist to enter information similar to that of a prescription, with the pharmacist’s identification in the ‘prescriber’ field (refer to the Ministry of Health and Long- Term Care’s Executive Officer communications). As this is a billing mechanism (which also creates documentation for the patient) it should not be interpreted as prescribing the vaccine, as pharmacists do not have the independent authority to do so.